Revenue has updated its guidance on foreign entity classification for tax purposes to include information relating to section 1009A TCA 1997 which was introduced by Finance Act 2025. This new section provides that a foreign body corporate and its members will be taxed in Ireland in the same manner as a partnership and its partners where it is substantially similar to an Irish partnership.
The updated guidance includes additional details on the application of caselaw tests and removes information now included in the guidance on the taxation of partnerships.